Soaking in a bath tub, Michael Phelps wears nothing but a small swimsuit, a pair of goggles atop his head and a stern look. Next to him, a pair of blue jeans spills from a Louis Vuitton bag.

It marks a sophisticated turn as a pitchman for the Baltimore swimmer fresh off setting a record for the most Olympic medals earned in a career. But there’s speculation his appearance in an advertising campaign shot by famed photographer Annie Leibovitz for the high-end designer’s latest campaign could run him afoul of International Olympic Committee rules.

The photos — there’s also one of Phelps in a three-piece suit, seated on a couch with Larisa Latynina, the gymnast whose Olympic medal record he broke after 48 years — began appearing on the Internet on Aug. 7, and quickly spread to gossip, fashion and sports sites.

Questions followed about whether their un-attributed release constituted a violation of the much-talked-about Rule 40, which prevents Olympians from appearing in unapproved ads for a period surrounding the games.

The International Olympic Committee has yet to comment on the issue. A spokeswoman for the organization referred questions to the U.S. Olympic Committee. USOC spokesman Patrick Sandusky said he reviewed the matter and determined Phelps remains in compliance because he did not authorize the early release of the photos.

Phelps’ agent, Peter Carlisle, dismissed any suggestion that Phelps had violated the rule — an act which, according to IOC documentation, could lead to an athlete being stripped of his medals.

Carlisle tweeted Friday that “Rule 40 applies to athletes who permit use of their name during the Games; it doesn't apply to unauthorized uses (which, unfortunately, are common).” Phelps retweeted him later.

Calls to Louis Vuitton’s United States headquarters were not returned Monday, but representatives have told other media outlets the company was not responsible for the leak. Leibovitz’s agent said the same thing, according to the media reports.

The “Beyond the Limits” campaign officially launched Aug 16 — a day after the IOC’s prohibition ended — and now is featured prominently on Louis Vuitton’s website, where Phelps discusses his goal of growing swimming through his foundation, and guides users through an interactive video.

Rule 40 became subject of social media ridicule during the games, as athletes lamented — often angrily — a rule that prevented them from thanking existing sponsors, or making money from new ones.

IOC documentation on the rule says its goal is the protect the Olympics’ amateur roots by preventing “ambush marketing” in which companies attempt to create a connection to the games without sponsoring them.

Track and field athletes were especially dismayed, with many tweeting their grievances along with the hash tags #rule40 and #wedemandchange.

Middle distance runner Leo Manzano told his Facebook followers that he’d been forced to take down comments on his running shoes and their performance because of the rule. Manteo Mitchell, who became a hero of the London games by completing his leg of the 4X400 relay with a broken fibula, expressed his opposition via Twitter: “I am PROUD to represent my Country... but at the end of the day... THIS IS MY JOB!!!!!!” Both Manzano and Mitchell are sponsored by Nike. Adidas sponsored the London games.

Athletes and their agents are responsible for preventing a company from violating Rule 40, according to IOC guidelines. While a company that sponsored an Olympian could reference that fact on its website, it could not tout the relationship on its home page and was not allowed to “refer expressly to the Games apart from to make a proportionate, factual statement that the athlete is an Olympian.”

Phelps, who returned to Baltimore late last week and has been spotted in Canton and at Meadowbrook aquatic center, where he has long trained, moved quickly to add to his endorsement portfolio following what he has promised was his final competition. In addition to the Louis Vuitton deal, he’s agreed to appear in a Golf Channel series and reached a deal with General Mills to once again appear on the cover of Wheaties cereal boxes.